Walden Environmental Engineering, PLLC (Walden) was retained to assess the amount of hazardous chemicals handled, used and stored at a private aircraft services facility in Suffolk County, New York. The chemical inventory evaluation was intended to determine if annual Tier II chemical inventory reporting would be required in accord with the Emergency Planning and Community Right to Know Act (EPCRA). As the facility was being operated under new management, the facility manager was unfamiliar with Right to Know Tier II reporting regulatory requirements for the area and retained Walden to assist.
The facility management provided Walden with an inventory of all chemicals at the facility so that Walden could evaluate both the chemical inventory amounts and the composition of the chemicals stored and used at the Facility, from Safety Data Sheets (SDSs). This was done to determine if the facility inventory included any reportable hazardous substances that exceeded the Threshold Planning Quantity (TPQ). Additional consideration was given with regards to regulations pertaining to the temporary storage of a portion of the fuel at this facility in mobile fueling vehicles as opposed to stationary aboveground or underground storage tanks (ASTs/USTs).
Based on the findings of the chemical inventory data evaluation, it was determined that the Facility was required to file an annual Tier II report. The Tier II Report was submitted electronically through the E-Plan database system that New York State uses to accept online submission of Tier II chemical inventory information. The E-Plan system filing provided notification to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) and gave access to the Facility Tier II Report submission. Only additional reporting to the local fire department having jurisdiction over the Facility had to be completed via a hard copy submittal.
Although Walden was hired just past the March 1st filing deadline for the reporting year, Walden was able to successfully complete the filing for the facility prior to any regulatory violation issues.